This Privacy Policy (“Policy”) applies to persons who use Tiet Kiem Nhom Application (“TKN App”), provided by Trust Circle Vietnam Company Limited (“Trust Circle”), a company established under the law of Vietnam, having its head office at SB-02, 151 Ton Dat Tien, Garden Court 1, Tan Phong Ward, District 7, Ho Chi Minh City.

This Policy is an integral part of the Terms and Conditions. By installing the TKN App, you acknowledge that you have read carefully and agreed with this Policy.



1.1              Information You Provide to Us

We collect information you provide directly to us, such as when you create or modify your account, request on-demand services, contact customer support, or otherwise communicate with us. This information may include: name, date of birth, identity card’s information, occupation, email, phone number, address, profile picture, payment method, and other information you choose to provide.

1.2              Information We Collect Through Your Use of the TKN App

When you use the TKN App, we collect information about you in the following categories:

  • Transaction Information:We collect transaction details related to your use of the TKN App, including the date and time the the TKN App is used, the Groups that you are a member, and other related transaction details.
  • Usage and Preference Information: We collect information about how you interact with the TKN App, preferences expressed, and settings chosen.
  • Device Information:We may collect information about your mobile device, including, for example, the hardware model, operating system and version, software and file names and versions, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information.
  • Log Information:When you interact with the TKN App, we collect server logs, which may include information like device IP address, access dates and times, app features, app crashes and other system activity.
  • Contact Information:If you permit the TKN App to access the address book on your device through the permission system used by your mobile platform, we may access and store names and contact information from your address book to facilitate social interactions through the TKN App and for other purposes described in this Policy or at the time of consent for collection.



We may use the information we collect in accordance with this Policy to:

  • Provide, maintain, and improve the TKN App, including, for example, to facilitate payments, send receipts, provide products and services you request (and send related information), develop new features, provide customer support, develop safety features, authenticate users, and send product updates and administrative messages;
  • Perform internal operations, including, for example, to prevent fraud and abuse of the TKN App; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends;
  • Send or facilitate communications between you and other users of the TKN App;
  • Send you communications we think will be of interest to you, including information about products, services, promotions, news, and events of Trust Circle and/or the TKN App, where permissible and according to applicable laws; and to process contest, sweepstake, or other promotion entries and fulfill any related awards; and
  • Personalize and improve the TKN App, including to provide or recommend features, content, social connections, referrals, and advertisements.

We may transfer the information described in this Policy to, and process and store it in Vietnam and other countries, some of which may have less protective data protection laws than Vietnam. Where this is the case, we will take appropriate measures to protect your personal information in accordance with this Policy.



We may share the information we collect about you as described in this Policy or as described at the time of collection or sharing, including as follows:

3.1              Through the TKN App

We may share your information:

  • With third parties to provide you with a service you requested or promotional offering made by a third party or us;
  • With the general public if you submit content in a public forum, such as comments, social media posts, or other features of the TKN App that are viewable by the public;
  • With third parties with whom you choose to let us share information, for example other apps or websites that integrate with the TKN App; and
  • With other users which were or are in a same Group with you.

3.2              Other Important Sharing

We may share your information:

  • With Trust Circle’s subsidiaries and affiliated entities that provide services or conduct data processing on our behalf, or for data centralization and/or logistics purposes;
  • With vendors, consultants, marketing partners, and other service providers who need access to such information to carry out work on our behalf;
  • In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
  • With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with this Policy, our Terms and Conditions, or other policies, or to protect the rights, property, or safety of Trust Circle or others;
  • In connection with, or during negotiations of, any merger, sale of Trust Circle’s assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company; and
  • If we otherwise notify you and you consent to the sharing.

3.3              Social Sharing Features

the TKN App may integrate with social sharing features and other related tools which let you share actions you take on the TKN App with other apps, sites, or media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service.

3.4              Analytics and Advertising the TKN App Provided by Others

We may allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, and other technologies to identify your device when you use the TKN App, as well as when you visit other online sites and services.



4.1              Account Information

You may correct your account information at any time by logging into your online or in-app account. If you wish to correct any of your other information, please contact us at [email protected] Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if you have a standing credit or debt on your account, or if we believe you have committed fraud or violated our Terms and Conditions, your information may be reserved until the matter is resolved.

4.2              Access Rights

Trust Circle will comply with individual’s requests regarding access, correction, and/or deletion of the personal data it stores in accordance with applicable law.

4.3              Promotional Communications

You may opt out of receiving promotional messages from us by following the instructions in those messages. If you opt out, we may still send you non-promotional communications, such as those about your account, about the TKN App you have requested, or our ongoing business relations.


We reserve the right to change this Policy from time to time. If we make significant changes in the way we treat your personal information, or to the Policy, we will provide you notice through the TKN App or by other appropriate means. Your continued use of the TKN App after such notice constitutes your consent to the changes. You are encouraged to periodically review the Policy for the latest information on our privacy practices.



If you have any questions about this Policy, you may contact us by written communication to our address at SB-02, 151 Ton Dat Tien, Garden Court 1, Tan Phong Ward, District 7, Ho Chi Minh City or by email to [email protected] or by calling to our customer services number at 1900 6449.